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2018 (5) TMI 1761 - AT - Income TaxBenefit of Tonnage Tax Scheme u/s 115VP/115VR - Offshore installations - Held that:- rigs are qualifying ships u/s 115VD - Since the learned CIT (Appeals) while deciding the issue in favour of the assessee has followed the decision of the Tribunal in assessee’s own case as well as the decision of Hon’ble Jurisdictional High Court, therefore, in absence of any contrary material brought to our notice by the learned Departmental Representative, we find no infirmity in the order of the learned CIT (Appeals) allowing the ground raised by the assessee. - Decided against the revenue. Addition on account of difference in receipt as per TDS Certificate and amount shown in P&L A/c - Held that:- The assessee has properly reconciled the receipts vis-à-vis the amount shown in the profit and loss account. The learned Departmental Representative could not controvert the factual finding of the learned CIT (Appeals) on this issue. - No additions - Decided against the revenue. Bad debts - amount written off - Held that:- The reason assigned by the AO that assessee is having business relationship with these parties in later years is incorrect because in subsequent years there were no such business relationship continued with M/s Frontier Drilling as evident from the various documents and in view of the Arbitration award. - Claim of bad debts allowed - Decided against the revenue. Disallowance u/s 14A - no expenditure has been incurred for earning the dividend income - Held that:- when the assessee gets tonnage tax benefit under section 115VP / 115VR of the Act, the addition under section 14A read with Rule 8D is not at all required. - Decided against the revenue.
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